Privacy Notice and GDPR
Please read this information before your initial appointment.
The General Data Protection Regulation (GDPR) is new legislation which came into effect in 2018. Under this law you have a right to know what information I collect, how I use it and the circumstances in which it may be shared.
The personal information you provide to Fearless Counselling and Coaching will be used for legitimate business interests, that is, to provide you with a professional counselling service.
Before your initial appointment you will be directed to this page of my website. You will be asked to sign that you have seen this privacy notice to confirm that you have received and understood this policy .
Your Personal Data
Information kept includes:
Your signed acknowledgment of the privacy notice
Your signed counselling agreement
Brief record of each counselling session (which may contain sensitive personal data – see below)
A personal information sheet
Sensitive Personal Data (“Special Category Data”)
Some of the information collected may be sensitive personal data including ethnic origin, religious beliefs and physical and mental health. Such data will only be used to provide a counselling service in accordance with legal obligations. Sensitive personal data is stored as part of your clinical notes which are anonymised with a unique code. Your personal information links to your clinical notes using a unique code. This code is stored in a separate location and password protected.
My lawful basis for holding and using your personal information
The GDPR states that I must have a lawful basis for processing your personal data. There are different lawful bases depending on the stage at which I am processing your data. I have explained these below: If you have had therapy with me and it has now ended, I will use legitimate interest as my lawful basis for holding and using your personal information. If you are currently having therapy or if you are in contact with me to consider therapy, I will process your personal data where it is necessary for the performance of our contract. The GDPR also makes sure that I look after any sensitive personal information that you may disclose to me appropriately. This type of information is called ‘special category personal information’. The lawful basis for me processing any special categories of personal information is that it is for provision of health treatment (in this case counselling) and necessary for a contract with a health professional (in this case, a contract between me and you).
How I use your information
When you contact me with an enquiry about my counselling services I will collect information to help me satisfy your enquiry. This will include your name, address, email address and telephone number. Alternatively, your GP or other health professional may send me your details when making a referral or a parent or trusted individual may give me your details when making an enquiry on your behalf. If you decide not to proceed I will ensure all your personal data is deleted within twelve months. If you would like me to delete this information sooner, just let me know.
While you are accessing counselling everything that happens in your therapy session remains confidential. That confidentiality will only be broken if:
I will discuss aspects of the work with my Supervisor, but your identity will remain protected.
I may be required to discuss the work if required by law (this is very rare). For example, if you discussed acts of terrorism or serious crime or risk of serious harm to others, I would discuss this with the police. Similarly, if you reveal information about children or vulnerable adults being seriously at risk, I would report to that to the relevant authorities.
If subpoenaed to give evidence in court, I would have to do so.
I may contact your GP or other medical professionals if I believe that you were likely to cause serious injury to yourself.
I will always try to speak to you first about disclosing information, unless there are safeguarding issues that prevent this.
I will keep a record of your personal details to help the counselling services run smoothly. These details are kept securely using WriteUpp clinical software (www.writeupp.com) and are not shared with any third party. I will keep written notes of each session, these are kept within this software system. For security reasons I do not retain text messages for more than three months. If there is relevant information contained in a text message I will copy it and store it in your personal notes in Writeupp. Likewise, any email correspondence will be deleted after three months if it is not important.
After counselling has ended.
Once counselling has ended your records will be kept for five years from the end of our contact with each other and are then securely destroyed. If you want me to delete your information sooner than this, please tell me.
Data/Why it is kept
- Name, date of birth, occupation / Basic information about yourself that helps me to get to know you.
- Address, email address and telephone number / I use this as a way of contacting you about my sessions. - Address is also kept in case I felt you were at risk and needed to request a police safety check.
- Emergency contact / In case anything happens to you within our session, for instance if you become suddenly ill and I needed to contact someone.
- GP Details / If I felt you were at risk than I may need to contact your GP. Where possible, and if appropriate, I will discuss this with you first.
- Session Notes / Standard professional procedure requires summary notes to be made of each session which refreshes your counsellor's memory of what was discussed in sessions.
- Sensitive Personal Data ("Special Category Data") / This information helps me to get to know you and make an initial assessment of your circumstances including any history mental health issues.
- Session Notes – Data I have a legal obligation to keep
I am required by my insurance company to keep session notes for a period of 5 years after the end of therapy, after which they are destroyed by either deletion or shredding.
What are your rights?
You have a right to request to see or have amended any personal information I may keep about you. You also have the right to request that I delete information that I hold about you. You also have the right to object to the processing and use of your personal data.
What information do you share?
I will not share any information about you with other organisations or people, except in the following situations:
Consent – I may share your information with other professionals whom you have requested or agreed I should contact.
Serious harm – I may share your information with the relevant authorities if I have reason to believe that this may prevent serious harm being caused to you or another person.
Clinical Executor – If for any reason I become incapacitated and unable to work your information will be passed onto my Clinical Executor so they can contact you and make suitable arrangements.
Compliance with the law – for instance if I am required by a court of law
Third party recipients of personal data
I sometimes share personal data with third parties, for example, where I have contracted with a supplier to carry out specific tasks. In such cases I have carefully selected which partners I work with. I take great care to ensure that I have a contract with the third party that states what they are allowed to do with the data I share with them. I ensure that they do not use your information in any way other than the task for which they have been contracted.
How your data is stored
Paper forms and correspondence are stored in a locked filing cabinet. All electronic records are encrypted and require password access. Your telephone number may be kept in my mobile phone which is also password protected.
Your identifiable information is kept separately from any session notes and are linked by a unique number.
How long I keep it for
For legal reasons I keep session notes for five years after the end of therapy which is the time frame my insurance company requires. After this they are destroyed, either by shredding or deletion.
The following will be shredded or deleted within three months of our work finishing:
Personal information form
Your phone number from my mobile phone
Emails regarding appointment arrangements
I am registered with the Information Commissioner’s Office [Insert registration number]. My phone number is: 07484372780. My email address is: email@example.com
Data Protection Accountability
If you wish to complain about how your data is handled, in the first instance contact, Rozanna Niazi.
If your complaint is not resolved to your satisfaction you can contact the Information Commissions Office at https://ico.org.uk/concerns/handling/ or call 0303 123 1113.
Confidentiality & Zoom
This is a very important aspect of the counselling relationship. Everything that is discussed in the counselling session is kept in the strictest confidence. If we are working through online counselling I will be using Zoom which has end-to-end encryption. For security both the platform I will be using, Zoom, and my laptop have end-to-end encryption. Recording functionality will be disabled, and meetings will be password protected to prevent unauthorised participants from entering.
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